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Countries

MaltaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Malta runs on the European rulebook. Data may go abroad once the right paperwork is in place, and there is no general rule that it must stay on the island. Two things break that. Online gaming companies must keep their core systems inside Europe. And any Maltese company that keeps its books abroad must still keep a copy of its accounts in Malta.
The catch: The easy answer stops being true in three places. First, online gaming, which is Malta's biggest regulated industry: a licensed operator's 'key technical setup' — including the player database, the financial database and the control system — must sit in Malta or another European Economic Area country, unless the Malta Gaming Authority approves another location one case at a time. The same operator must also run a live mirror of its essential regulatory data that the Authority can reach at any moment, including physically. Second, company law: if a company keeps its accounting records outside Malta, it must still send to Malta, and keep in Malta, accounts and returns good enough to show the financial position at least every six months. Third, government: the public administration's own cloud policy says cloud services should as a rule be inside the European Union or European Economic Area, and anything classified must go on the government's own cloud. Banking, payments, insurance, securities, health, education and mapping have no storage-location rule that we could find, checked 18 August 2026.
Does this apply to me?: Yes. Malta's Data Protection Act reaches a company with no office in Malta if it offers goods or services to people in Malta, or watches their behaviour in Malta. There is no size or revenue threshold. There is no extra Maltese representative to appoint beyond the one the European rules already require of companies based outside Europe.High confidence
Can the data leave the country?: In general, yes. Malta has no law saying personal data must be stored on the island. It follows the European Union rules: send data outside Europe once you have an approved destination or the right contract. Three areas override that. Online gaming is the big one, and it is Malta's flagship industry.High confidence
What do I have to do to send it abroad?: Use the European toolkit. Send data to a country the European Commission has approved, or sign the European standard contract, or use approved group-wide rules. Malta adds nothing on top. Malta's own minister has a power to restrict transfers of named categories of data, but has never used it, so the list of Maltese restrictions is empty today.High confidence
Who enforces this — and are they actually working?: The Information and Data Protection Commissioner. It is real, staffed and issuing decisions: its public register shows around nineteen decisions published in 2026 and thirty-eight in 2025. The fines are small by European standards — most sit between about 2,000 and 20,000 euros (roughly $2,300 to $23,000). The gaming regulator is the harder one, and it cancels licences.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling. The floor: company accounting records for ten years, tax and value-added-tax records for at least six years, and anti-money-laundering records for five years. The ceiling: the European rule that you delete personal data once you no longer need it. Where they clash, the specific Maltese law that orders you to keep something wins, because keeping it is then a legal duty.High confidence
What happens when something goes wrong?: Count three clocks, and they do not line up. Seventy-two hours to tell the privacy regulator about a personal data breach. Twenty-four hours to send a first warning about a serious cyber incident, then seventy-two hours for the full report and one month for the final one. Phone and internet companies have their own separate duty to report straight away.High confidence
What's the trap?: Five things that are not in the summary. A child in Malta is thirteen, not sixteen. Health and biometric research needs the regulator's written permission before you start, not just a risk assessment. Copying someone's identity card is restricted. Leaking a client secret can be a crime, not a fine. And the gaming regulator can keep personal data forever, in a law that says so out loud.High confidence
What's about to change?: Three dated changes. On 1 January 2027 a new law stops insurers, banks and employers asking about a cancer diagnosis once enough time has passed since treatment. On 12 January 2027 European rules make cloud switching and data export fees free. And Malta's artificial intelligence rules started phasing in on 2 August 2026, with the privacy regulator now policing the market.High confidence
Hardest industry wall: All industries — Att dwar il-Kumpaniji (Kap. 386), artikolu 163

ArmeniaChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Dormant

In one paragraph: Armenia lets personal data leave, but only to a country on an official approved list of 53 states, or with case-by-case permission from the privacy regulator. That regulator has had no boss since February 2026 and the largest fine it can impose is about 1,300 US dollars. The real constraints are elsewhere: government data sent to a foreign cloud must keep a backup copy inside Armenia, and banking and medical secrecy sit outside the privacy law entirely.
The catch: The approved-country list is worthless in three places. Government bodies must keep an in-country backup of anything they put in a cloud abroad. Bank, notarial, lawyer and insurance secrets are carved out of the privacy law and are governed by their own secrecy statutes, which list exhaustively who may see the data and do not mention foreign cloud providers. And leaking medical secrets is a crime that can put a named individual in prison, not just a fine on the company.
Does this apply to me?: Probably not, if you have nothing in Armenia. The privacy law describes who it covers by naming Armenian public bodies, companies and individuals who process personal data. It contains no clause saying it follows Armenians' data abroad, and no rule requiring a foreign company to appoint someone inside Armenia. There is no size or revenue threshold either, so a one-person Armenian business is caught exactly like a bank.Medium confidence
Can the data leave the country?: Yes, with paperwork. Armenia runs an approved-country list: if the destination is on it, you can send data with no permission from anyone. The list is real and populated — 53 countries, including all of the European Union, the United Kingdom, Canada, Japan, South Korea, Israel, Georgia and Russia. Sending data anywhere else needs written permission from the privacy regulator first, and that regulator currently has nobody in the chair. Three sectors override this entirely: government, banking-type secrets, and health.High confidence
What do I have to do to send it abroad?: The model is an approved list, and the list is full. Fifty-three countries were approved on 8 July 2024 and that decision has never been changed. If your destination is on it you need nothing — no standard contract, no filing, no fee. If it is not on it, you must write to the regulator before you send anything, attach the contract you plan to sign, and wait up to 30 days for a yes or a no.High confidence
Who enforces this — and are they actually working?: On paper, the Personal Data Protection Agency inside the Ministry of Justice. In practice, nobody right now: its head resigned with effect from 24 February 2026 and no replacement appointment has been published. In more than eleven years the agency has published exactly one general decision — the approved-country list. Two other regulators are genuinely working: the Central Bank supervises banks, payment firms, insurers and securities, and a brand-new Information Systems Regulatory Commission was appointed in March and April 2026 to police cybersecurity and state computer systems.Medium confidence
How long must I keep it, and when must I delete it?: The floor is five years for anything that proves your tax position. The ceiling is not a number — it is a principle: you must destroy or block personal data as soon as you no longer need it for the purpose you collected it for. Two hard clocks sit inside that principle. If someone withdraws consent you have ten working days to destroy their data, then three more working days to tell them you did. If you spot unlawful processing you have three working days to fix it or destroy the data.High confidence
What happens when something goes wrong?: Count three clocks. Under the privacy law, if data leaks out of your electronic systems you must immediately publish a public announcement about it and at the same time tell the Armenian police and the privacy regulator — there is no grace period and no threshold. If you run a system in a sector the state calls vital, you have 24 hours to tell the cybersecurity regulator, 72 hours to send an update, two days to warn the people affected, and one month to file a final report. Both sets of duties can bite at once.High confidence
What's the trap?: Five things that will ruin your week. One: a data leak must be announced publicly and reported to the police, not just to the regulator. Two: encryption is legally compulsory, not a best practice, and failing to use it is its own separate fine. Three: before you process biometric or sensitive data you must notify the regulator in advance and wait to be entered in its register. Four: to process a dead person's data you need the consent of all of their legal heirs. Five: a child is anyone under 16 here, not 13 and not 18.High confidence
What's about to change?: Armenia rewired its digital rulebook in December 2025 and the deadlines land through 2026, 2027 and 2028. Rules for cyber incidents and for state computer systems are already live. Detailed technical rules are due by January 2027, internal cybersecurity policies and risk assessments by July 2027, and security certificates for critical systems by January 2028. The change most likely to catch someone out is not a new law at all: the approved-country list can be rewritten by one official's signature.High confidence
Hardest industry wall: Government — «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում

The eight framework questions answered for each selected country
Question	MaltaChecked 18 August 2026	ArmeniaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork Work: Medium Enforcement: Dormant
In one paragraph	Malta runs on the European rulebook. Data may go abroad once the right paperwork is in place, and there is no general rule that it must stay on the island. Two things break that. Online gaming companies must keep their core systems inside Europe. And any Maltese company that keeps its books abroad must still keep a copy of its accounts in Malta.	Armenia lets personal data leave, but only to a country on an official approved list of 53 states, or with case-by-case permission from the privacy regulator. That regulator has had no boss since February 2026 and the largest fine it can impose is about 1,300 US dollars. The real constraints are elsewhere: government data sent to a foreign cloud must keep a backup copy inside Armenia, and banking and medical secrecy sit outside the privacy law entirely.
The catch	The easy answer stops being true in three places. First, online gaming, which is Malta's biggest regulated industry: a licensed operator's 'key technical setup' — including the player database, the financial database and the control system — must sit in Malta or another European Economic Area country, unless the Malta Gaming Authority approves another location one case at a time. The same operator must also run a live mirror of its essential regulatory data that the Authority can reach at any moment, including physically. Second, company law: if a company keeps its accounting records outside Malta, it must still send to Malta, and keep in Malta, accounts and returns good enough to show the financial position at least every six months. Third, government: the public administration's own cloud policy says cloud services should as a rule be inside the European Union or European Economic Area, and anything classified must go on the government's own cloud. Banking, payments, insurance, securities, health, education and mapping have no storage-location rule that we could find, checked 18 August 2026.	The approved-country list is worthless in three places. Government bodies must keep an in-country backup of anything they put in a cloud abroad. Bank, notarial, lawyer and insurance secrets are carved out of the privacy law and are governed by their own secrecy statutes, which list exhaustively who may see the data and do not mention foreign cloud providers. And leaking medical secrets is a crime that can put a named individual in prison, not just a fine on the company.
Does this apply to me?	Yes. Malta's Data Protection Act reaches a company with no office in Malta if it offers goods or services to people in Malta, or watches their behaviour in Malta. There is no size or revenue threshold. There is no extra Maltese representative to appoint beyond the one the European rules already require of companies based outside Europe.High confidence	Probably not, if you have nothing in Armenia. The privacy law describes who it covers by naming Armenian public bodies, companies and individuals who process personal data. It contains no clause saying it follows Armenians' data abroad, and no rule requiring a foreign company to appoint someone inside Armenia. There is no size or revenue threshold either, so a one-person Armenian business is caught exactly like a bank.Medium confidence
Can the data leave the country?	In general, yes. Malta has no law saying personal data must be stored on the island. It follows the European Union rules: send data outside Europe once you have an approved destination or the right contract. Three areas override that. Online gaming is the big one, and it is Malta's flagship industry.High confidence	Yes, with paperwork. Armenia runs an approved-country list: if the destination is on it, you can send data with no permission from anyone. The list is real and populated — 53 countries, including all of the European Union, the United Kingdom, Canada, Japan, South Korea, Israel, Georgia and Russia. Sending data anywhere else needs written permission from the privacy regulator first, and that regulator currently has nobody in the chair. Three sectors override this entirely: government, banking-type secrets, and health.High confidence
What do I have to do to send it abroad?	Use the European toolkit. Send data to a country the European Commission has approved, or sign the European standard contract, or use approved group-wide rules. Malta adds nothing on top. Malta's own minister has a power to restrict transfers of named categories of data, but has never used it, so the list of Maltese restrictions is empty today.High confidence	The model is an approved list, and the list is full. Fifty-three countries were approved on 8 July 2024 and that decision has never been changed. If your destination is on it you need nothing — no standard contract, no filing, no fee. If it is not on it, you must write to the regulator before you send anything, attach the contract you plan to sign, and wait up to 30 days for a yes or a no.High confidence
Who enforces this — and are they actually working?	The Information and Data Protection Commissioner. It is real, staffed and issuing decisions: its public register shows around nineteen decisions published in 2026 and thirty-eight in 2025. The fines are small by European standards — most sit between about 2,000 and 20,000 euros (roughly $2,300 to $23,000). The gaming regulator is the harder one, and it cancels licences.High confidence	On paper, the Personal Data Protection Agency inside the Ministry of Justice. In practice, nobody right now: its head resigned with effect from 24 February 2026 and no replacement appointment has been published. In more than eleven years the agency has published exactly one general decision — the approved-country list. Two other regulators are genuinely working: the Central Bank supervises banks, payment firms, insurers and securities, and a brand-new Information Systems Regulatory Commission was appointed in March and April 2026 to police cybersecurity and state computer systems.Medium confidence
How long must I keep it, and when must I delete it?	There is a floor and a ceiling. The floor: company accounting records for ten years, tax and value-added-tax records for at least six years, and anti-money-laundering records for five years. The ceiling: the European rule that you delete personal data once you no longer need it. Where they clash, the specific Maltese law that orders you to keep something wins, because keeping it is then a legal duty.High confidence	The floor is five years for anything that proves your tax position. The ceiling is not a number — it is a principle: you must destroy or block personal data as soon as you no longer need it for the purpose you collected it for. Two hard clocks sit inside that principle. If someone withdraws consent you have ten working days to destroy their data, then three more working days to tell them you did. If you spot unlawful processing you have three working days to fix it or destroy the data.High confidence
What happens when something goes wrong?	Count three clocks, and they do not line up. Seventy-two hours to tell the privacy regulator about a personal data breach. Twenty-four hours to send a first warning about a serious cyber incident, then seventy-two hours for the full report and one month for the final one. Phone and internet companies have their own separate duty to report straight away.High confidence	Count three clocks. Under the privacy law, if data leaks out of your electronic systems you must immediately publish a public announcement about it and at the same time tell the Armenian police and the privacy regulator — there is no grace period and no threshold. If you run a system in a sector the state calls vital, you have 24 hours to tell the cybersecurity regulator, 72 hours to send an update, two days to warn the people affected, and one month to file a final report. Both sets of duties can bite at once.High confidence
What's the trap?	Five things that are not in the summary. A child in Malta is thirteen, not sixteen. Health and biometric research needs the regulator's written permission before you start, not just a risk assessment. Copying someone's identity card is restricted. Leaking a client secret can be a crime, not a fine. And the gaming regulator can keep personal data forever, in a law that says so out loud.High confidence	Five things that will ruin your week. One: a data leak must be announced publicly and reported to the police, not just to the regulator. Two: encryption is legally compulsory, not a best practice, and failing to use it is its own separate fine. Three: before you process biometric or sensitive data you must notify the regulator in advance and wait to be entered in its register. Four: to process a dead person's data you need the consent of all of their legal heirs. Five: a child is anyone under 16 here, not 13 and not 18.High confidence
What's about to change?	Three dated changes. On 1 January 2027 a new law stops insurers, banks and employers asking about a cancer diagnosis once enough time has passed since treatment. On 12 January 2027 European rules make cloud switching and data export fees free. And Malta's artificial intelligence rules started phasing in on 2 August 2026, with the privacy regulator now policing the market.High confidence	Armenia rewired its digital rulebook in December 2025 and the deadlines land through 2026, 2027 and 2028. Rules for cyber incidents and for state computer systems are already live. Detailed technical rules are due by January 2027, internal cybersecurity policies and risk assessments by July 2027, and security certificates for critical systems by January 2028. The change most likely to catch someone out is not a new law at all: the approved-country list can be rewritten by one official's signature.High confidence
Hardest industry wall	All industries — Att dwar il-Kumpaniji (Kap. 386), artikolu 163	Government — «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում